SCHEDULE C 

 Subpart F Indemnity 

 Lessor has assumed that neither Lessor nor any of the Tax Indemnitees will
be subject to United States income tax under Subpart F of the United States Internal Revenue Code of 1986, as amended (the “Code”), with respect to income from the Lease nor will the Aircraft be treated as “United States
property” for purposes of Subpart F of the Code (“Subpart F Assumption”). 

  




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| (a) | Usage Covenant: To support Lessor’s or other applicable Tax Indemnitee’s entitlement to the treatment contemplated by the Subpart F Assumption, Lessee agrees
that in each calendar year during the Term the Aircraft will be used for the transportation of passengers or property between airports at least one of which is located outside of the United States and the Aircraft will be used predominantly outside
the United States.  |

 For the purpose of paragraph (a), the Aircraft will be considered to be used predominantly
outside the United States if either: 

 1) the Aircraft will be located outside the United States more than \*\*\*\*\* per cent of the
time; or 

 2) more than \*\*\*\*\* per cent of the miles traversed in the use of the Aircraft will be traversed outside the United
States. 

 For the purpose of paragraph (a), references to the United States include the Commonwealth of Puerto Rico and the
possessions of the United States (American Samoa, The Commonwealth of the Northern Mariana Islands, Guam, and The U. S. Virgin Islands) and references to Aircraft include a separate reference to each Engine.